Comparison by AO between qualitatively different agreements with completely different terms not appropriate

CIT Vs Khandelwal Shringi & Co. (Rajasthan High Court)

In this case CIT(A) held that he do not agree with decision of the assessing officer to use the agreement to sell 13.25 hectares of land at Rs. 8.25 crores that was never executed, and the offer to purchase 10.21 hectares, a part of the same 13.25 hectares, for Rs. 7.00 crores that was not accepted and taken to a logical conclusion, as evidence of fair market value of the land in question. Besides these two the assessing officer did not bring any other evidence to sh

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